This section contains the nature of the case and procedural background.

The Petitioner was convicted on tax charges when he failed to both, register his firearm business with the IRS and remit an annual excise tax of $200 to the IRS. This was in violation of §20 of the National Firearm Statute. Other provisions of the Act required the Petitioner to pay $200 per sale of a firearm. The Petitioner asserts that the taxes in question are not within the scope of Congress' taxing power because they were designed to impede the accessibility and transaction of certain firearms - matters that are more cognizably under a state's policy power, not Congress' taxing power. To support his claim, the Petitioner presents a calculation of fees he is subjected to under the Act; this total exceeds the actual value of the firearm therefore, reducing its worth and also its marketability. The U.S. Supreme Court affirmed the decision of the District Court against the Petitioner.

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